https://www.taxtmi.com/acts?id=6289 Payments defined as technical fees for technical, managerial or consultancy services may be taxed in the payer's State of source, but if the recipient is the beneficial owner such source taxation shall not exceed 10 per cent of the gross amount. Fees connected to a recipient's permanent establishment or independent personal services in the source State are excluded from this source withholding and are governed by the provisions on business profits or independent personal services. Inflated payments arising from special relationships are confined to the arm's-length amount for treaty application. en-us Sat, 19 Jan 2008 22:45:54 +0530 Sat, 23 Nov 2024 11:55:59 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=6289 Payments defined as technical fees for technical, managerial or consultancy services may be taxed in the payer's State of source, but if the recipient is the beneficial owner such source taxation shall not exceed 10 per cent of the gross amount. Fees connected to a recipient's permanent establishment or independent personal services in the source State are excluded from this source withholding and are governed by the provisions on business profits or independent personal services. Inflated payments arising from special relationships are confined to the arm's-length amount for treaty application. Act-Rules DTAA Sat, 19 Jan 2008 22:45:54 +0530 https://www.taxtmi.com/acts?id=6289